Executive summary
Date(s) of inspection
- September 2023
Aim of inspection
The aim of this inspection was to sample the development of the capability of the chemistry team within the Pre-Operations (pre-ops) function. The purpose of the pre-ops chemistry team is to lead on the development of:
- chemistry capabilities on site, including sampling and analysis laboratories;
- the delivery of chemistry documents (operating instructions) that define the operations that will be undertaken by chemistry operators and technicians;
- training of chemistry operators and to the wider operational community;
- chemistry support to commissioning;
- arrangements for chemical safety; and
- chemical specifications.
The inspection assessed whether the development of these activities will ensure that chemistry risks are reduced as low as reasonably practicable (ALARP) during construction, commissioning and operation.
Subject(s) of inspection
- LC10 – Training – Rating: Green
- LC12 – Duly authorised and other suitably qualified and experienced persons – Rating: Green
- LC14 – Safety documentation – Rating: Green
- LC28 – Examination, inspection, maintenance and testing – Rating: Green
Key findings, inspector’s opinions and reasons for judgement made
I judged the adequacy of NNB Generation Company (HPC) Ltd’s (NNB GenCo) arrangements and their implementation against the expectations associated with Licence Condition (LC) 10 (training), LC12 (duly authorised and other suitably qualified and experienced persons), LC14 (safety documentation), and LC28 (examination, inspection, maintenance and testing). This inspection was devised to gain confidence that the pre-ops chemistry function is developing adequately to be able to carry out the activities that it will be required to perform on site as Hinkley Point C (HPC) continues to be constructed. As such, the degree with which NNB GenCo adhered to the licence conditions reflects this fact, and they were used to inform the inspection judgement.
The NNB GenCo pre-ops chemistry team has developed detailed plans for the requirements of relevant chemistry legislation that they will be responsible for delivering as the construction of HPC continues. Despite some problems due to it being the first team within the pre-ops organisation to produce such work, I was content that sufficient progress is being made, and the pre-ops chemistry team will have adequate arrangements in place to fulfil its requirements.
The NNB GenCo pre-ops chemistry team has developed a suite of documents to train its chemistry technicians and engineers, to enable them to achieve suitably qualified and experienced personnel (SQEP) status ahead of the time when the project will require them to fulfil certain duties. Despite some problems due to it being the first team within the pre-ops organisation to produce such training material and SQEP guides, and a lack of coordination with the commissioning team, I was content that sufficient progress is being made to train and qualify the members of the team.
NNB GenCo has identified the need for a temporary laboratory facility to provide for commissioning and pre-ops analysis, but the proposed location for this laboratory is not ideal. NNB GenCo acknowledged my comments in this area and agreed to further consider the laboratory location. I will continue to engage on this during my routine engagements.
The NNB GenCo pre-ops chemistry team has a clear understanding of the role it will play in ensuring that installed plant will be stored correctly, and has plans in place to support this important work. Despite an apparent lack of coordination with the commissioning team, I was content that sufficient progress is being made in this area.
Conclusion
Overall, I consider that the NNB GenCo pre-ops chemistry team is making good progress in all areas to comply with the relevant chemical legislation. Despite some areas for improvement, and uncertainty about the suitability of the proposed temporary laboratory, I rated LCs 10, 12, 14 and 28 as green (no formal action) to be warranted for this inspection. I will track progress with the actions raised on NNB GenCo during this inspection through my routine interactions with the licensee.